K Number
K093383
Manufacturer
Date Cleared
2010-07-06

(249 days)

Product Code
Regulation Number
862.2570
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The NucliSENS EasyQ Analyzer and the accompanying NucliSENS EasyQ Director software are intended for in vitro diagnostic use in conjunction with FDA-cleared or approved NucliSENS assay protocols. The user shall be a properly trained laboratory technician familiar with performing nucleic acid assays. The analyzer is intended to measure fluorescent readings from molecular beacon probes binding to amplified RNA or DNA in samples containing NucliSENS EasyQ assay reagents while controlling the temperature of the samples. The NucliSENS EasyQ Director software is intended to control instrument operations and organize the assays to be performed. In addition, the software is intended to automatically calculate results for each test request based on raw measurement data, the data reduction algorithm specified for the assay, and the batch parameters of the reagents used for the test.

Device Description

The NucliSENS EasyQ System includes principally the instrument, NucliSENS EasyQ® Analyzer, and the software, consisting of NucliSENS EasyQ" Director Software 2.6 used in combination with assay specific NucliSENS EasyQ® assay protocols. The system also requires use of the instrument, NucliSENS EasyQ® Incubator II.

The NucliSENS EasyQ® Analyzer (Analyzer) is an automated, temperature-controlled fluorescence analyzer instrument designed for batch processing of up to 96 samples per run. Amplification of nucleic acid targets is detected by means of sequence-specific probes which each fluoresce upon binding of the probe to its target. The Analyzer contains a plate carrier, which is designed to keep temperature constant at the required assay temperature. The Analyzer is a specially designed fluorescent reader using an optical system based on direct and focused illumination, designed to prevent crosstalk, Specific filters are used to select the appropriate wavelength for both excitation and emission of the molecular beacons used in the assay specified for each test. The filter selection is controlled by the attached PC and is a function of the assay protocol applied to a specified test.

Once sample tube strips have been loaded into plate carrier block of the Analyzer, the instrument moves the first tube into position over the light source. The Analyzer the light source upward through the bottom of the sample tube. The light causes the molecular beacons (in the assay reagent mixture) to emit light. Through the use of a mirror, the emitted light is directed through an optical filter to a photomultiplier tube where the fluorescence reading is taken. The next sample is then moved into position and the process is repeated. The intensity of the emitted light is measured for each sample and the process is repeated for each test as the run progresses, generating a series of data points for each sample that form fluorescence curves.

The Analyzer is used in combination with NucliSENS EasyQ® Director software) and assay-specific EasyQ® assay protocol software (assay protocols), loaded on a NucliSENS EasyQ computer with a keyboard and screen interface. The Director Software is used for instrument control and data collection. In combination with assay-specific "assay protocols", the Director Software also performs automated result calculation and reporting based on the analysis of real-time fluorescence signal curves measured by the Analyzer. Results may be qualitative or quantitative, depending on the design of the assay and the assay protocol. Results available to the operator include both the qualitative or quantitative test result and the graph of the fluorescence data points (data curves).

AI/ML Overview

This document describes the NucliSENS EasyQ® System, which includes the NucliSENS EasyQ® Analyzer and NucliSENS EasyQ® Director Software 2.6. The submission is for a 510(k) clearance, indicating a claim of substantial equivalence to a predicate device, rather than a novel device requiring extensive clinical trials for efficacy. The core of this submission focuses on changes to an already cleared system, specifically a software upgrade (Director 2.5 to 2.6) and an instrument replacement (EasyQ Incubator to EasyQ Incubator II).

Therefore, the "study" described is primarily a validation of these changes to maintain equivalence, not a standalone performance study of the entire system as a new device.

Here's a breakdown of the requested information based on the provided text:


Acceptance Criteria and Device Performance

The document does not explicitly state numerical acceptance criteria in a table format for performance metrics like sensitivity or specificity for the entire system as a new device. Instead, the submission hinges on the concept of substantial equivalence to an already cleared system (NucliSENS EasyQ® System with Enterovirus v1.1 Assay, K063261) and a predicate device (Applied Biosystems 7500 Fast Dx Real-Time PCR Instrument, K082562).

For the changes in this submission (software upgrade and incubator replacement), the acceptance criterion is implied to be that the updated system performs equivalently to the previously cleared system, specifically with the NucliSENS EasyQ® Enterovirus v1.1 Assay.

Acceptance Criterion (Implied for Changes)Reported Device Performance (for validated changes)
Maintain equivalent performance to the previously cleared system (K063261)"Validated by internal in-silico testing using a panel of input data selected from prior test results, and representative of all foreseeable classes of test specimens."

Study Details for Device Performance

  1. Sample Size Used for the Test Set and Data Provenance:

    • Sample Size: The document mentions "a panel of input data selected from prior test results." A specific number for this panel is not provided.
    • Data Provenance: The data was "selected from prior test results," implying it was retrospective data. The country of origin is not specified but given bioMérieux's global presence, it's likely a multinational company with data potentially from various regions, though typically for regulatory submissions in the US, data is often from US or similar regulatory environments.
  2. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

    • The document implies an "internal in-silico testing" approach. There is no mention of a specific number of experts or their qualifications for establishing ground truth for this validation. The "prior test results" would have had their ground truth established during the original validation of the Enterovirus assay.
  3. Adjudication Method for the Test Set:

    • No adjudication method (e.g., 2+1, 3+1) is mentioned or implied, as the validation was "internal in-silico testing" using pre-existing data.
  4. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    • No, an MRMC comparative effectiveness study was not conducted as part of this submission. The validation focused on the technical performance of the upgraded software and instrument, not a human-in-the-loop comparison.
  5. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:

    • Yes, the validation described as "internal in-silico testing" using a panel of input data effectively represents a standalone algorithm-only performance assessment for the software upgrade. It confirms the software's ability to correctly process existing data and calculate results as expected, without human interaction during that assessment phase.
  6. Type of Ground Truth Used:

    • The ground truth for the test data (the "panel of input data selected from prior test results") would have been established previously for the NucliSENS EasyQ® Enterovirus v1.1 Assay. For nucleic acid amplification tests, this typically involves clinical diagnosis combined with confirmatory laboratory methods (e.g., culture, sequencing, or a validated reference PCR) to define true positive/negative samples. The document does not explicitly state the ground truth for these specific prior test results.
  7. Sample Size for the Training Set:

    • The document describes "internal in-silico testing using a panel of input data selected from prior test results." This panel was used for validation of the changes (software and incubator). There is no mention of a separate "training set" size in this submission section, as the software is an upgrade, not a newly developed prediction algorithm that would typically require a distinct training phase in this context. The core data reduction algorithm itself would have been developed and "trained" during the original development of the NucliSENS EasyQ® Director Software, but details are not provided here.
  8. How the Ground Truth for the Training Set Was Established:

    • As no specific "training set" for the software upgrade validation is mentioned, this information is not available in the provided text. The original software development would have relied on internally generated or retrospectively collected data with established outcomes or known characteristics (e.g., spiked samples, clinical samples with confirmed results), but these details are not part of this 510(k) summary.

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Image /page/0/Picture/0 description: The image shows the logo for bioMerieux. The logo consists of the word "BIOMERIEUX" in block letters, with a black circle above the letters. A thin line runs vertically through the circle and the letters. The logo is simple and modern.

JUL - 6 2010

510(k) SUMMARY

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

The assigned 510(k) number is: K093383.

Name of device

NucliSENS EasyQ® System, including the following components:

Instrumentation and Software

NucliSENS EasyQ® Analyzer NucliSENS EasyQ® Director Software 2.6 NucliSENS EasyQ® assay protocol software included in the NucliSENS EasyQ® assay kit for the specific assay used NucliSENS EasyQ® Incubator II NucliSENS EasyQ® Computer and peripherals (monitor, printer, keyboard, mouse) NucliSENS miniMAG®

Reference is made to the performance of the system as previously cleared for the NucliSENS EasyQ® Enterovirus v1.1 Assay (K063261).

Classification

Product code: OOI Real Time Nucleic Acid Amplification System Regulation: 862.2570 Instrumentation for clinical multiplex test systems Device Class: Class II

Device to which equivalence is claimed

The device, which is the subject of this submission, is claimed equivalent to the Applied Biosystems 7500 Fast Dx Real-Time PCR Instrument with the SDS Software version 1.4 (K082562).

Intended Use of the Device

In vitro diagnostic medical device.

The NucliSENS EasyQ Analyzer and the accompanying NucliSENS EasyQ Director software are intended for in vitro diagnostic use in conjunction with FDA-cleared or approved NucliSENS assay protocols. The user shall be a properly trained laboratory technician familiar with performing nucleic acid assays. The analyzer is intended to measure fluorescent readings from molecular beacon probes binding to amplified RNA or DNA in samples containing NucliSENS EasyQ assay reagents while controlling the temperature of the samples. The NucliSENS EasyQ Director software is intended to control instrument operations and organize the assays to be performed. In addition, the software is intended to automatically calculate results for each test request based on raw measurement data, the data reduction algorithm specified for the assay, and the batch parameters of the reagents used for the test.

Description of the Device

The NucliSENS EasyQ System includes principally the instrument, NucliSENS EasyQ® Analyzer, and the software, consisting of NucliSENS EasyQ" Director Software 2.6 used in combination with assay

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specific NucliSENS EasyQ® assay protocols. The system also requires use of the instrument, NucliSENS EasyQ® Incubator II.

The NucliSENS EasyQ® Analyzer (Analyzer) is an automated, temperature-controlled fluorescence analyzer instrument designed for batch processing of up to 96 samples per run. Amplification of nucleic acid targets is detected by means of sequence-specific probes which each fluoresce upon binding of the probe to its target. The Analyzer contains a plate carrier, which is designed to keep temperature constant at the required assay temperature. The Analyzer is a specially designed fluorescent reader using an optical system based on direct and focused illumination, designed to prevent crosstalk, Specific filters are used to select the appropriate wavelength for both excitation and emission of the molecular beacons used in the assay specified for each test. The filter selection is controlled by the attached PC and is a function of the assay protocol applied to a specified test.

Once sample tube strips have been loaded into plate carrier block of the Analyzer, the instrument moves the first tube into position over the light source. The Analyzer the light source upward through the bottom of the sample tube. The light causes the molecular beacons (in the assay reagent mixture) to emit light. Through the use of a mirror, the emitted light is directed through an optical filter to a photomultiplier tube where the fluorescence reading is taken. The next sample is then moved into position and the process is repeated. The intensity of the emitted light is measured for each sample and the process is repeated for each test as the run progresses, generating a series of data points for each sample that form fluorescence curves.

The Analyzer is used in combination with NucliSENS EasyQ® Director software) and assay-specific EasyQ® assay protocol software (assay protocols), loaded on a NucliSENS EasyQ computer with a keyboard and screen interface. The Director Software is used for instrument control and data collection. In combination with assay-specific "assay protocols", the Director Software also performs automated result calculation and reporting based on the analysis of real-time fluorescence signal curves measured by the Analyzer. Results may be qualitative or quantitative, depending on the design of the assay and the assay protocol. Results available to the operator include both the qualitative or quantitative test result and the graph of the fluorescence data points (data curves).

The device which is the subject of this submission is largely unchanged from the NucliSENS EasyQ System used in conjunction with the assay NucliSENS EasyQ® Enterovirus v1.1, which received 510(k) clearance from FDA (K063261) on 23-Jun-2008,

The following assay components and characteristics are unchanged from the system as cleared in K063261:

  • intended use and indications for use .
  • � test principle
  • modes of operation .
  • . reagents
  • t controls
  • . performance characteristics
  • . EasyQ Analyzer instrument
  • . MiniMAG instrument
  • . EasyQ Enterovirus v1.1 assay protocol software
  • Instructions for Use, except administrative changes as needed to reference current versions of ● software and instrumentation (listed below)

Changes to the assay system are as follows:

  • a cleared instrument is being replaced with another instrument of equivalent performance (EasyQ . Incubator -> EasyQ Incubator II)
  • a key software component is being upgraded (Director 2.5 -> 2.6) .

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  • the software upgrade enhances the assay's ease of use by enabling sorting of test requests according to several key test parameters (sample ID, priority, sample volume, etc.) and by allowing the operator to order a retest from the original sample
  • use of the upgraded software in connection with the EasyQ Enterovirus v1.1 assay has been validated by internal in-silico testing using a panel of input data selected from prior test results, and representative of all foreseeable classes of test specimens

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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird-like figure, with three curved lines representing the wings or body.

· Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-0609 Silver Spring, MD 20993-0002

BIOMÉRIEUX c/o Jocelyn Jennings, R.A.C. Senior Manager, Regulatory Affairs 100 Rodolphe Street Durham, NC 27712

JUL 0 6 2010

K093383 Trade/Device Name: NucliSENS EasyQ® System 21CFR §862.2570 Regulation Number: Instrumentation for clinical multiplex test systems Regulation Name: Regulatory Class: Class II Product Code: OOI June 23, 2010 Dated: June 28, 2010 Received:

Dear Ms. Jennings:

Re:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into class II (Special Controls), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Parts 801 and 809); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and, if applicable, the as over radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. This letter will allow you to begin marketing your device as described in your Section

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Page 2 - Jocelyn Jennings

510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Sall actgn

Sally A. Hojvat, M.Sc., F Director Division of Microbiology Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

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INDICATIONS FOR USE STATEMENT

510(k) Number (if known): K093383

Device Name: NucliSENS EasyQ® System, including the following components: .

Instrumentation and Software

NucliSENS EasyQ® Analyzer NucliSENS EasyQ® Director Software 2.6 NucliSENS EasyQ® assay protocol software included in the NucliSENS EasyQ® assay kit for the specific assay used -NucliSENS EasyQ® Incubator II NucliSENS EasyQ® Computer and peripherals (monitor, printer, keyboard, mouse) NucliSENS miniMAG®

Indications For Use: The NucliSENS EasyQ Analyzer and the accompanying NucliSENS EasyQ Director software are intended for in vitro diagnostic use in coniunction with FDA-cleared or approved NucliSENS assay protocols. The user shall be a properly trained laboratory technician familiar with performing nucleic acid assays. The analyzer is intended to measure fluorescent readings from molecular beacon probes binding to amplified RNA or DNA in samples containing NucliSENS EasyQ assay reagents while controlling the temperature of the samples. The NucliSENS EasyQ Director software is intended to control instrument operations and organize the assays to be performed. In addition, the software is intended to automatically calculate results for each test request based on raw measurement data, the data reduction algorithm specified for the assay, and the batch parameters of the reagents used for the test.

Over-The-Counter Use Prescription Use X AND/OR (21 CFR 801 Subpart C) (Part 21 CFR 801 Subpart D)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of In Vitro Device Evaluation and Safety

Ule Schiff
Division Sign-Off

Division Sign-Off

Office of In Vitro Diagnostic Device Evaluation and Safety

k 093383 510(k).

§ 862.2570 Instrumentation for clinical multiplex test systems.

(a)
Identification. Instrumentation for clinical multiplex test systems is a device intended to measure and sort multiple signals generated by an assay from a clinical sample. This instrumentation is used with a specific assay to measure multiple similar analytes that establish a single indicator to aid in diagnosis. Such instrumentation may be compatible with more than one specific assay. The device includes a signal reader unit, and may also integrate reagent handling, hybridization, washing, dedicated instrument control, and other hardware components, as well as raw data storage mechanisms, data acquisition software, and software to process detected signals.(b)
Classification. Class II (special controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9. The special control is FDA's guidance document entitled “Class II Special Controls Guidance Document: Instrumentation for Clinical Multiplex Test Systems.” See § 862.1(d) for the availability of this guidance document.